Energy Policy ] (]]]]) ]]]]]]

Contents lists available at SciVerse ScienceDirect

Energy Policy
journal homepage: www.elsevier.com/locate/enpol

Preface

Low carbon fuel policy and analysis

1. Introduction
The transition to non-petroleum fuels is proceeding slowly.
Petroleum continues to dominate the transportation fuels market,
accounting for over 95% of total supply. It has many advantages: It
is very energy dense, easily transportable, and relatively abundant. But it also has large downsides: High carbon and toxic
emissions when combusted and most of the lowest-cost sources
are concentrated in a politically unstable region, the Middle East.
Only Brazil has successfully shifted a large share of its transportation energy away from petroleum.
There are many reasons for policy intervention. These include the
classic market failures of ignoring climate change and local air
pollution, and under-investing in R&D (Jaffe et al., 2005; Nemet and
Kammen, 2007). But equally important are the many market failures
and market conditions that riddle the energy system, many of them
unique to transportation, that result in consumer and business
decisions not in the best interest of society. These market conditions
include the network effects of additional coordination among fuel
producers, vehicle manufacturers, and fuel distributors (Leiby and
Rubin, 2004; Sperling and Gordon, 2009; Struben and Sterman,
2008); energy security externalities related to petroleum imports
(Greene and Leiby, 2006; Greene et al., 2007; Leiby, 2008; U.S. EPA,
2011b); long time horizons needed for return on investments in fuel
infrastructure (NRC, 2008); the lack of fuel-on-fuel competition; the
diffuse nature of the biofuel industries; and the market power of oil
companies and OPEC countries. Energy markets are particularly
inefcient and ineffective at addressing end-use technology efciency and demand reduction (Greene et al., 2011; Greene, 2011).
Transportation needs to contribute a sizable share of greenhouse gas (GHG) emission reductions if climate stabilization goals
are to be achieved. Signicant penetration by advanced vehicle
technologies and alternative fuels would be needed by the 2015
2020 timeframe given the long lag time of technology uptake
(IEA, 2012; Kyle et al., 2011; IPCC, 2007; Greene et al., 2011;

Greene, 2011; Pacala and Socolow, 2004; Schafer

et al., 2009;
Vimmerstedt et al., 2012). Market-based policies are, in theory,
the most economically efcient means of achieving GHG reductions. Pure market instruments, such as carbon taxes and carbon
cap-and-trade, are likely to provide the long-term policy framework for continuing reductions in GHG emissions and are key to
inserting a price signal for GHG emissions in energy marketsbut
by themselves are inadequate to achieve large reductions in GHG
emissions in the near- and medium-term, especially with respect
to transportation.
Policy analyses suggest that very stringent caps (Yeh et al.,

2008) or taxes (Schafer

et al., 2009), well beyond what is likely to
be politically acceptable, will be needed to incentivize signicant
0301-4215/$ - see front matter & 2013 Elsevier Ltd. All rights reserved.
http://dx.doi.org/10.1016/j.enpol.2013.01.008

penetration by low-carbon vehicle/fuel technologies. In an analysis of the carbon cap-and-trade program adopted by the US
House of Representatives in 2007 (but later rejected by the US
Senate), the U.S. Environmental Protection Agency (EPA) found
that the policy would raise gasoline prices by $0.16 and $0.81 per
gallon in 2015 and 2050, respectively, which would not be
sufcient to induce consumers to reduce fuel use signicantly
or purchase alternative fuels or vehicles (U.S. EPA, 2010). Holland
et al. (2009) suggest an efcient carbon pricing policy (equivalent
to carbon trading) would need to raise fuel prices by $1.15 to
$31.16 per gallon gasoline to reduce transportation fuel use and
GHG emissions by 20 to 24 percent.
Because pure market-based policies have limited effects, a
broader mix of policies is needed if transportation GHG emissions
are to be reduced signicantly in the next few decades (Sperling
and Nichols, 2012). Vehicle efciency (and tailpipe GHG emission)
standards are being adopted around the world (see, for example,
U.S. EPA (2011a, 2011c), the European Commission (EC, 2009),
and the recent global fuel economy initiative led by the United
Nation Environment Programme (http://www.unep.org/trans
port/programmes/gfei/index.asp). The recent history of vehicle
efciency standards in several markets and the aggressiveness of
new standards suggest that they will be a highly effective policy
tool in reducing vehicle GHG emissions (Karplus and Paltsev,
2012). Policies addressing vehicle use and decarbonization of
fuels have been less successful, in the latter case due in part to
the fuel du jour pattern of past policies and the lack of a robust,
long-term policy framework (Sperling and Gordon, 2009; NRC,
2011).
Here we take up the challenge of policy to decarbonize
transportation fuels. Below we provide an overview of the
principal existing policy initiatives to decarbonize transportation
fuels, focusing on those that incorporate performance-based
elements.

2. U.S. Renewable Fuel Standard

The U.S. Energy Independence and Security Act (EISA) of 2007
requires transportation energy suppliers to sell 36 billion gallons
(bgal) of biofuels annually by 2022. At least 21 bgal must be
advanced biofuels, including 16 bgal cellulosic biofuel and 1bgal
biomass-based diesel. No more than 15 bgal can come from
starch-derived ethanol such as corn ethanol (Table 1). These fuel
requirements, codied as the Renewable Fuel Standard (RFS2),
have GHG emission reduction thresholds for each category of
biofuels, including explicit consideration of emissions from global
land use conversions (often known as indirect land use change, or

Preface / Energy Policy ] (]]]]) ]]]]]]

Table 1
RFS2 biofuel requirements (in billion gallons), as set initially by EISA (2007) and later revised by EPA.
Advanced biofuelb (minimum volume)

EISA

2011
2012
2013
2022a

EPA

2011
2012
2013d

Cellulosic

Biomass-based dieselc

Other

Total

0.25
0.50
1.00
16.00

0.80
1.00

0.30
0.50
0.75
4.00

1.35
2.00
2.75
21.00

0.0066
0.00865

0.8
1.0
1.28

Corn-based ethanol
(maximum volume)

Total renewable
fuels

12.6
13.2
13.8
15.0

13.95
15.20
16.55
36.00

1.35
2.0

13.95
15.20

EISA 2014 to 2021 requirements are not shown here.

In 2011 and 2012, most of the advanced biofuel requirement was met by biomass-based diesel and sugarcane ethanol (categorized under other).
c
Biomass-based diesel requirements after 2012 are to be determined by EPA through a future rulemaking, but must be no less than 1.0 billion gallons.
d
As this article goes to press, EPA has not yet published 2013 volumetric requirements except for biomass-based diesel.
b

iLUC, emissions). These GHG thresholds are based on life-cycle

emission accounting. The policy allows banking and trading of
credits using renewable identication numbers (RIN).
Each year, EPA is required to adjust the RFS2 cellulosic biofuel
requirement for that year based on the volume projected to be
available during the following year, using U.S. Energy Information Administration projections and industry assessments of
production capability. In 2011 and 2012, EPA greatly lowered
the required volume of annual cellulosic biofuel, well below
levels established by EISA, but kept the requirements for
advanced biofuel and total renewable biofuel the same as those
established by EISA 2007 (Table 1). In response to delayed
investments, EPA adjusted the 500 million gallon 2012 requirement downward to 8.65 million gallons, as indicated in Table 1,
with companies required to pay penalties for shortfalls. Only
20,069 gallons of cellulosic ethanol and 1024 gallons of cellulosic
diesel were commercially delivered in the rst 11 months of
2012, falling far short of the 8.65 million gallons required by U.S.
EPA (2012).

3. Californias LCFS
A low carbon fuel standard (LCFS), adopted by California in
2009 and implemented in 2010, requires a 10 percent reduction
by 2020 in the carbon intensity of transportation fuels sold in the
state (CARB, 2009). Like the RFS2, the LCFS relies on lifecycle
assessment of GHGs, expressed as CO2 equivalents per unit of fuel
energy (gCO2/MJ). Lifecycle emissions are dened to include all
GHGs emitted during extraction, cultivation, land use conversion,
processing, transport and distribution, and fuel use.
The LCFS differs from the RFS in that it allows all transport fuel
alternatives, including biofuels, compressed natural gas, electricity, and hydrogen, to be used to meet compliance targets. It is
also different in calculating a continuum of GHG emissions in
accordance with actual lifecycle emissions of a particular energy
path, unlike the RFS2 which assigns biofuels to only three fuel
categorieswith 20, 50, and 60 percent GHG reductions relative
to gasoline and diesel fuel for renewable, advanced, and cellulosic
biofuels, respectively.
The use of lifecycle measurements is important when considering alternative fuels because emissions upstream of vehicles
represent almost the total lifecycle emissions of biofuels, electricity, and hydrogen, compared to conventional gasoline and
diesel fuel, where upstream emissions account for only about 20
percent (Delucchi, 2003; GREET (2010)). Upstream emissions of
very heavy oils and oil sands can also be much greater than those

for conventional gasoline and diesel fuel, because much more

energy is expended in extraction, production, and rening
(Brandt, 2011; Brandt and Farrell, 2007; Charpentier et al., 2009).
The LCFS utilizes lifecycle measurements to stimulate innovation. By targeting GHG reductions throughout the entire supply
chain including those with emissions higher than conventional
gasoline and diesel (such as electricity from coal) the lifecyclebased LCFS encourages continuous innovation in every step of the
supply chain. For instance, the LCFS encourages reductions in
their mining and processing, including capturing and sequestering carbon emissions.
Regulated parties have considerable exibility under the LCFS.
They can comply by (1) increasing the supply of low-carbon fuels;
(2) reducing the carbon intensity of fuels they supply; or (3) purchasing credits from other regulated parties that exceed the
compliance (Sperling and Yeh, 2009). Thus, Californias LCFS is a
hybrid policy instrument in the sense that it includes not only
regulatory features, but also market features, allowing companies
to trade and bank carbon reduction credits. The RFS2 also has a
market feature, allowing companies to trade compliance volumes,
but in a more limited fashion because only biofuels can comply
and emission categories are more lumpy.
A review of Californias LCFS by Yeh and Witcover (2012)
found that fuel sold in California during the rst 1.5 years of the
LCFS program exceeded the initially modest requirements (0.25
percent carbon intensity reduction in 2011 and 0.5 percent in
2012), with 86 percent of credits generated from ethanol, primarily corn based, and the remaining 14 percent coming from
natural gas and biodiesel. That report also found the average LCFS
credit prices in August 2012 to be $13/MT CO2e, adding about
0.1cents per gallon to the production cost of gasoline.

4. European Union Fuel Quality Directive, FQD

In April 2009, the European Commission revised its Fuel
Quality Directive to focus on GHG emissions from transport fuels,
and incorporated LCFS-like features into the Directive. It established a 6 percent reduction target for the carbon intensity of
transportation fuel supplied to the European Union. This carbon
intensity reduction can be achieved by supplying any low carbon
fuel, such as hydrogen or electricity, but it is widely expected that
the bulk of the target will be met through the use of biofuels. The
revised FQD was designed to be consistent with their Renewable
Energy Directive (RED), which sets a mandatory 20 percent
renewables target for the EU energy mix by 2020, including
a specic requirement for 10 percent renewable energy in

Preface / Energy Policy ] (]]]]) ]]]]]]

transportation energy. There are no limits on eligible feedstocks

under the Directive, although only energy options surpassing a
minimum GHG threshold on a lifecycle basis can qualify.
Unlike the US, where most biofuels are domestically supplied
corn-based ethanol, the majority of EU biofuel requirements have
been met to date with biodiesel (80 percent of the total biofuels
market on an energy basis). Around 80 percent of the biodiesel is
produced domestically primarily from Germany, France, Spain,
and Benelux, with about 2/3 of the domestic biodiesel made from
rapeseed. The remaining 20 percent is soybean-based biodiesel
imported from the US and Brazil and palm oil based biodiesel
imported from Malaysia and Indonesia.
The FQD goes beyond LCFS-like policies in establishing sustainability criteria for biofuels. It states that biofuels produced on
high biodiversity and high-carbon land cannot count towards the
GHG intensity reduction obligation. The FQD requires European
Member States to enforce both the overall targets and the
sustainability conditions.

5. British Columbia (Renewable and Low-Carbon Fuel

Requirement Regulation, RLCFRR)
In January 2010, British Columbia implemented the Renewable
and Low Carbon Fuel Requirements Regulation (RLCFRR). The
RLCFRR will reduce the carbon intensity of transportation fuels
through two sets of rules: the Renewable Fuel Requirement,
requiring 5 percent renewable content in gasoline in 2010
onward and 4 percent renewable content in diesel in 2012
onward; and the Low Carbon Fuel Requirement, which requires
10 percent reduction in carbon intensity of transportation fuels by
2020.

6. Design and analysis challenges for LCFS-like policies

Implementation of the LCFS in California, the FQD in Europe,
and future LCFS-like programs elsewhere, confront a variety of
challenges (Sperling and Yeh 2009, 2010; Yeh and Sperling, 2010).
Some of these challenges are general to biofuel and GHG policies,
while some are related specically to the design of LCFS policies.
These challenges include the economic impacts of an LCFS
compared with other GHG policies (Holland et al., 2009, 2011);
impacts of low-carbon fuel policies on energy security due to
discouraging high-carbon fuels such as Canadian oil sands (Canes
and Murphy, 2009; Keuter, 2009); market mediated effects on the
net GHG performance of the LCFS policy due to leakage and
rebound effects (Chen and Khanna, 2012; Rajagopal et al., 2011)
and indirect land use change (Hertel et al., 2010); uncertainties of
fuel carbon intensities (Kaufman et al., 2010; Mullins et al., 2010;
Venkatesh et al., 2010); and the impacts on environmental and
social sustainability (Yeh et al., 2009; Rosegrant et al., 2008)
particularly on food prices (Tokgoz et al., 2012; FAO et al., 2011).
While the papers cited above provide valuable contributions, they
are not focused on policy design.
The papers contained in this special issue analyze various
aspects of an LCFS-like policy. These papers compare an LCFS with
other policy instruments that have the potential to signicantly
reduce transportation GHG emissions from fuel use, and propose
policy structures for an LCFS that would be most effective and
implementable. The topics addressed by these papers include
economic impacts (Huang et al., 2012), effects of credit trading
and banking on credit prices (Rubin and Leiby, 2012), energy
security impacts (Leiby and Rubin, 2012), impacts on total GHG
emission reductions (Rajagopal and Plevin; Huang et al., 2012),
role of uncertainty (Grifn et al., 2012), impacts and issues with

electricity for vehicles (Yang, 2012), and policy designs to address

land use changes associated with biofuels (Witcover et al.).
The scholarly literature, as well as real-world experience,
suggests that no single policy, including an LCFS, is likely by itself
to be effective at decarbonizing transportation fuels, at least not
in the foreseeable future. While the LCFS provides a durable
policy framework, it does not, for instance, address the chickenand-egg challenge of simultaneously bringing to market in a
temporal and spatial sense new forms of energy and new
vehicles that would use that energy. For a timely transition to
low-carbon, sustainable fuels, other complementary policies are
needed, coupled with innovative business models and coordinated investment actions. Overcoming the many start-up barriers,
market failures, and market conditions inhibiting innovations and
investments is one of the grand challenges facing our generation.
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Sonia Yeh n, Daniel Sperling

Institute of Transportation Studies, University of California, Davis, CA
95616, USA
E-mail addresses: slyeh@ucdavis.edu (S. Yeh),
dsperling@ucdavis.edu (D. Sperling)

Corresponding author. Tel.: 1 530 830 2544; fax: 1 530 752 6572.